BEFORE THE
POSTAL RATE COMMISSION.
WASHINGTON,
D.C. 20268-0001
RECEIVEC
I\UC20
3 3s F’M
Postal Rate and Fee Changes, 1997
‘97
NEWSPAPER ASSOCIATION OF AMERICA
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS MICHAEL D. BRADLEY
(NAAI USPS-T1 4-16-18)
August 20, 1997
The Newspaper Association of America hereby submits the attached
interrogatories
to United States Postal Service witness Michael D. Bradley (USPS-T-14)
and respectfully requests a timely and full response under oath.
Respectfully submitted,
NEWSPAPER ASSOCIATION OF AMERICA
By:
Robert J. Brinkmann
n..
William 8. Baker
NEWSPAPER ASSOCP.TION .OFAMERICA
WILEY,.REIN,&FIEL[)ING
529 14th Street, N.W.
Suite 440
Washington, D.C.
(202) 638-4792
1776 K Street, N.W.
Washington, DC 20006-2304
(202) 429-7255
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the instant document on all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
August 20,1997
William B. Baker
NEWSPAPER ASSOCIATION OF AMERICA
INTERROGATORIES
TO
UNITED STATES POSTAL SERVICE WITNESS
MICHAEL D. BRADLEY (USPS-T14-16-16)
NAAfUSPS-T14-16.
Please refer to your direct testimony at page 90, lines 24-28
a.
Please confirm that the variabilities for activities at non-MODS offices are
not calculated directly in any of your analyses.
b.
Please confirm that the variability for non-MODS offices is assumed to
equal the average or system variability from the MODS offices.
C.
Do non-MODS offices tend to be smaller mail processing facilities
compared to MODS oftices? Please provide the average size of the nonMODS office and the MODS offices in terms of mail volumes processed.
d.
Did you perform any econometric analyses with the size of the facility as
an independent variable? If no, please explain why not. If yes, please
provide copies of these analyses.
NAA/USPS-T14-17.
Please refer to the direct testimony of Postal Service Witness
Moden (USPS-T-4) at page 22, lines 17-20, where he states:
“In smaller facilities not covered by MODS, sorting schemes are often
simpler, the workroom floor is smaller, clerks have greater personal
knowledge of the local delivery area, and their very size makes it easier to
keep a steady flow of mail to operations such as manual flats and letters.”
a.
Is~thesteady flow-of maittooperatiomsuchesmanual
flats and tetters likely to result in a higher productivity for these activities at non-MODS
offices compared to the productivity of these activities at MODS offices?
If no, please explain why not.
b.
Please refer to your direct testimony at page 58, lines 14-17. Please
explain fully how a steady flow of mail to manual flat and letter operations
would affect the variabilities of these operations.
NEWSPAPER ASSOCIATION OF AMERICA
INTERROGATORIES
TO
UNITED STATES POSTAL SERVICE WITNESS
MICHAEL D. BRADLEY (USPS-T14-16-18)
NAAIUSPS-T14-18.
Moden (USPS-T-4)
a.
Please refer to the direct testimony of Postal Service Witness
at page 20, lines 23-30 and page 21, lines 1-5.
Do you agree that there is likely to be an adjustment period when
automated equipment is installed at a facility that delays achievement
optimal productivity? If no, please explain the basis for your
disagreement.
of
b.
If such an adjustment period exists, do you agree that productivity during
this adjustment period would be lower than the productivity achieved after
the adjustment period? If no, please explain the basis fior your
disagreement.
C.
Was any attempt made in your analysis to exclude data during the
adjustment period of a facility? If yes, please explain what data were
excluded and on what basis the exclusion was made. If no, please
explain why not.
d.
Was any attempt made in your analysis to segregate the effects of lower
productivities during the adjustment period or to otherwise account for the
effect of the learning curve on variabilities? If yes, please explain how
your analysis accounted for these effects. If no, please explain
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